The Announcement of the Personal Data Protection Authority Regarding Covid-19 Vaccines and PCR Tests

The Personal Data Protection Authority (“Authority”) announced its assessment regarding PCR test results and Covid-19 vaccines.

The relevant announcement highlights that personal health data such as PCR test results, vaccination status is of special nature within the scope of the Law on Protection of Personal Data (“LPPD”) and should be processed pursuant to the conditions established under art. 6 of the LPPD. Additionally, in order for eliminating a contagious disease as such, the Authority considers processing of personal data by public institutions and organizations authorized by law to avoid any circumstance threatening public security and public order such as pandemic is within the scope of the exceptions established under the LPPD art. 28/1(ç). Furthermore, any personal data processing activity that are not within the scope of or exceed the purpose of protecting public security and public order with respect to Covid-19 is subject to the LPPD.

Please find the full text of the announcement by the Authority here. (Turkish)